The word used S. 263 is “made” and not “received”. Hence, if the order under S. 263 was made/passed within the period of two years from the end of financial year in which order sought to be revised was passed, such an order would not be beyond the period of limitation prescribed under S. 263(2). Date on which order under S. 263 has been received by the assessee is not relevant for the purpose of reckoning period of limitation provided under S. 263(2)of the Income tax Act,1961.
[CIT v. Mohd. Meeran Shahul Hameed, (2022) 1 SCC 12]